E waste – II: India


India is the world’s third-largest generator of e-waste, after China and the United States.1 In 2019-20, India generated 1.01 million metric tonnes (MT) of e-waste.2 By 2023-24, that figure had jumped to 1.751 million MT—a staggering 73% increase in just five years.3

To put this in context: we’re generating e-waste at a rate that’s nearly doubled in less than half a decade. 65 Indian cities generate more than 60% of India’s total e-waste.4 Ten states account for 70% of the national total.4 States like Uttar Pradesh, Haryana, Telangana, and Uttarakhand have each collected and processed over 400,000 tonnes between 2016-17 and 2023-24.5

In 2019-20, India recycled just 22% of its e-waste.3 By 2023-24, that figure had climbed to 43%.3 Formal collection capacity expanded significantly over this period — though these figures are contested, given documented issues with EPR certificate fraud.5 However, 57% of e-waste (equivalent to 990,000 MT) still goes untreated every year.3 CSE’s Siddharth Ghanshyam Singh has said, “The recycling rate for e-waste remains low due to the authorities’ inability to effectively engage the various stakeholders involved.”3

Over 90% of e-waste in India is handled by the informal sector—untrained workers in urban slums who use rudimentary, dangerous processes without protective equipment.6 These processes include:7

  • Open burning of cables to recover copper, releasing toxic fumes
  • ​Acid baths to extract precious metals, contaminating water and soil
  • ​Manual dismantling without safety gear, exposing workers to heavy metals
  • Heating circuit boards over open flames to melt solder

The workers—often including children—are directly exposed to lead, mercury, cadmium, brominated flame retardants, and other toxins.8 The health consequences are severe: respiratory problems, neurological damage, kidney damage, developmental issues in children, and various cancers.8 Pollutants leach into surrounding communities’ air, water, soil, and food.7 Studies show that e-waste workers experience far greater health impacts than nearby residents, but even bystanders suffer from the pollution.8

Yet this informal sector persists because there’s money in it.6 Scrap dealers offer cash for old electronics; formal collection infrastructure is limited; and public awareness of proper disposal methods is low.9 A 2022 study of consumers in semi-urban Tamil Nadu found that while 76% scored well on a general six-question e-waste awareness composite, only 40.5% were even familiar with the term ‘e-waste’ itself — and 79.4% were entirely unaware of the e-waste legislation and rules in India. The gap between general awareness and specific, actionable knowledge has real consequences.9

How do people actually dispose of e-waste? The study revealed:9

  • 35% give their e-waste to scrap dealers (who often operate in the informal sector)
  • 21% dispose of it with regular household waste
  • Smaller percentages engage in proper recycling or collection programs

Anecdotally, I have noticed a fourth behaviour, which is to store old devices at home for lack of a better option to dispose of them properly. I do use my old phone as an alarm clock these days. My mother uses hers as a reading device. ​

The reasons for this behavior are clear: lack of convenient collection points, insufficient awareness of formal systems, and the absence of economic incentives.11 When people do dispose of electronics, they often choose the path of least resistance—the scrap dealer who comes to the door, or the trash bin.9

EPR
If e-waste is valuable, dangerous, and growing, the obvious question is why it’s still handled so poorly. The short answer is incentives.10 The long answer is that we’ve built systems that reward disposal, speed, and convenience—while making responsible recycling slow, confusing, or invisible.10

EPR is one of the most interesting environmental policies I’ve worked around, and is based on a simple principle: entities that place products on the market are made responsible for managing those products at end of life.11 Electronics are considered well suited to EPR because producers are identifiable, products are traceable, and end-of-life impacts are significant.11

Electronics contain hazardous materials that impose real public health and environmental costs when improperly handled.78 At the same time, they contain valuable recoverable materials.11 Without regulation, neither cost nor value is fully reflected in product pricing or business decisions. EPR attempts to internalise these externalities by shifting responsibility upstream—from municipalities and informal workers to producers.11

In theory, a well‑designed EPR system for e‑waste should deliver several linked outcomes:12

  • Reduce unsafe disposal: By making producers responsible for collection and treatment, the policy aims to move waste out of dumps, open burning and backyard acid leaching, and into controlled facilities that meet environmental and occupational standards.
  • Increase recycling rates: Targets and obligations should push more material into authorised collection and recycling channels, improving national recycling performance relative to the global average.
  • Encourage better product design: When end‑of‑life costs show up on producers’ balance sheets, they have reasons to reduce hazardous substances, design for disassembly, and extend product lifetimes through durability and reparability.11
  • Create stable financing: EPR fees, take‑back schemes, and producer responsibility organisations are meant to provide predictable funding for collection, transportation, recycling, and public awareness, instead of leaving municipalities and informal workers to absorb the costs.

On paper, this makes sense. In practice, it’s messy.

In India, producers meet EPR obligations largely through recycling certificates—essentially buying proof that someone, somewhere, recycled an equivalent amount of e-waste.13 This has improved formal recycling capacity, but it hasn’t meaningfully displaced the informal sector.14 Why? Because informal recyclers are faster, cheaper, and embedded in neighborhoods.6 They pay cash at the doorstep. Formal systems require awareness, transport, and effort.6


(You can also read about the economics of remanufacturing here)


India’s E-Waste Management Rules 2022 cover 106 different electrical and electronic equipment (EEE) products and their components. The 2022 rules recognise the following categories of stakeholders:15

  • Producers/Manufacturers: companies that make electronics for sale in India
  • Importers: those who bring electronics into India for sale
  • Bulk consumers: public institutions, offices, companies that generate large volumes of e-waste
  • Collection centers: authorized facilities for gathering e-waste from consumers
  • Recyclers: certified facilities that process e-waste using environmentally sound methods
  • Refurbishers: operations that repair and restore used electronics for resale

All these entities must register on a central portal developed by the Central Pollution Control Board (CPCB). Operating without registration is illegal.

Working smarter, not harder16
Kabadiwalas already operate the country’s most efficient reverse-logistics network. They have neighborhood-level reach, established trust, real-time pricing, and cash-based incentives that formal systems lack. Instead of trying to replace this network, policy should aim to formalize, standardize, and economically align it with safe recycling outcomes.

The core idea is simple: kabadiwalas should be treated as licensed collection and aggregation agents within the EPR framework. Producers would be mandated to route a fixed share of their collection targets through registered informal collectors. In return, kabadiwalas receive predictable payments for verified collection volumes—separate from the resale value of scrap—creating a financial incentive to hand material over to authorised recyclers rather than processing it themselves.

Today, informal workers earn more by dismantling, burning, or chemically processing electronics than by merely collecting them. Any incentive system that ignores this reality will fail. The solution is to decouple income from hazardous processing by paying for collection and safe transfer, not extraction.

This can be achieved through a per-kilogram collection fee, funded by EPR levies, paid directly to registered kabadiwalas once material is delivered to certified aggregation centers. Higher fees can be offered for high-risk items like lithium-ion batteries, CRTs, and circuit boards. Over time, this shifts the profit center upstream—from toxic backyard processing to safe logistics—without destroying livelihoods.

Importantly, traceability should flow forward, not backward. Once e-waste enters a certified channel, downstream recyclers and producers carry responsibility for compliance. Kabadiwalas should not be punished for system failures beyond their control; they should be paid for verified inputs.

Also: incentives alone are not enough. Mandates must close the loopholes that currently allow producers to meet EPR obligations on paper while real waste leaks into informal streams.

Regulations should require that:

  • A minimum percentage of e-waste collection occurs via registered decentralized collectors
  • Producers demonstrate geographic coverage, not just aggregate tonnage
  • Producers fund training, safety gear, and transition support for informal collectors they rely on

This forces formal systems to go where the waste actually is: homes, offices, and small businesses—not just bulk institutional sources.

This approach aligns incentives across the system:

  • Kabadiwalas earn stable, safer income
  • Producers meet real, verifiable EPR targets
  • Formal recyclers get cleaner, higher-quality feedstock
  • Cities and regulators reduce environmental and health damage without heavy enforcement

Most importantly, it acknowledges a basic truth: India does not lack recycling capacity—it lacks institutional pathways that convert existing economic behavior into safe outcomes. India’s e-waste crisis is not a failure of technology. It is a failure of incentives. Until policy rewards safe behavior as effectively as the informal market rewards unsafe extraction, the system will continue to leak toxicity.

The best part? Formal-informal partnership pilots in Delhi, Bangalore, and Pune, documented by GIZ in 2017, established that integration is operationally feasible. The document also reveals why this setup keeps failing: without mandatory EPR-linked financial flows from producers, these partnerships depend on goodwill and donor funding, and collapse once the initial support ends. The lesson isn’t that the model doesn’t work. It’s that it can’t be left to voluntary agreements.16

I worked on an e-waste project in 2013, and then on another one around 2018. The conversations hadn’t changed. The problems hadn’t changed. Even the language hadn’t changed. Everyone knew what wasn’t working — but the problems persisted. Incorporating the informal sector into the formal setup is one of the most inclusive and forward-looking steps the government can take, and it’s beyond time this was taken care of.

Sources

  1. India Electronic Waste Recycling Market Size and Growth Report — PS Market Research
  2. Managing India’s E-Scrap Is a Growing Challenge — Waste & Recycling Magazine
  3. India’s E-Waste Surges by 73% in 5 Years — Down to Earth
  4. Electronic Waste and India — Ministry of Electronics and IT (MeitY)
  5. India’s E-Waste Generation Doubles in 8 Years, but Processing Remains Skewed — Dataful
  6. Circular Economy and Household E-Waste Management in India: A Case Study on Informal E-Waste Collectors (Kabadiwalas) — Monash University
  7. The Emerging Environmental and Public Health Problem of Electronic Waste in India — Environmental Health Perspectives
  8. Health Consequences of Exposure to E-Waste — PMC / The Lancet
  9. Consumer Awareness and Perceptions about E-Waste Management — PMC / Journal of Family and Community Medicine
  10. Extended Producer Responsibility in Developing Economies — PMC
  11. Extended Producer Responsibility: Basic Facts and Key Principles — OECD
  12. Extended Producer Responsibility: Design, Functioning and Effects — PBL Netherlands Environmental Assessment Agency
  13. EPR Regulations in India: Rules, Importance and Guidelines — Attero
  14. India’s E-Waste EPR Model — Toxics Link (February 2026)
  15. E-Waste (Management) Rules, 2022 — Central Pollution Control Board
  16. Formal-Informal Partnerships in the Indian E-Waste Sector — GIZ (2017)

SEBI BRSR Explainer

The Business Responsibility and Sustainability Reporting (BRSR) is India’s most significant regulatory intervention in the domain of Environmental, Social, and Governance (ESG) disclosures. Introduced by the Securities and Exchange Board of India (SEBI) as the successor to the Business Responsibility Report (BRR), the BRSR mandates that the top 1,000 listed companies by market capitalisation submit structured, principle-based ESG disclosures as part of their annual reports. The framework is anchored in the National Guidelines on Responsible Business Conduct (NGRBC), issued by the Ministry of Corporate Affairs (MCA) in 2019. The NGRBC itself replaced the earlier National Voluntary Guidelines (NVGs) of 2011.

Before we go ahead, here’s a brief map:

  • BRSR: This is the framework.
  • BRSR Core: This is a subset of the framework
  • Industry Standards: This is an interpretation guide.
  • Assurance/Assessment: How the reports are verified.
  • Value Chain Disclosures: The expansion.

History1
India’s journey toward structured sustainability reporting began formally with the Business Responsibility Report (BRR), introduced under Regulation 34(2)(f) of the SEBI LODR Regulations, 2015. Initially applicable to the top 100 listed companies by market capitalisation from FY2013–14, the BRR was an attempt to institutionalise non-financial disclosures within the mainstream corporate reporting ecosystem.

However, the BRR had structural limitations that became increasingly apparent as the global ESG discourse matured:

  • The reporting format was largely narrative and open-ended, allowing considerable interpretive latitude that undermined comparability
  • There were no standardized quantitative metrics, making cross-company and cross-sector benchmarking virtually impossible
  • The framework had no third-party assurance requirements, leaving disclosures entirely self-declared and unverified
  • Coverage was limited to just 100 companies, leaving the vast majority of the Indian listed market outside the reporting ambit
  • The framework did not adequately reflect global developments such as the Paris Agreement, the UN Sustainable Development Goals (SDGs), or the rise of formal ESG investing frameworks

 In May 2021, SEBI issued a notification amending the LODR Regulations, formally announcing the discontinuation of the BRR and its replacement with the Business Responsibility and Sustainability Reporting (BRSR) framework. The transition was planned in a phased manner to allow companies adequate time to build institutional capacity:

  • FY2021–22: Voluntary phase — the top 1,000 listed companies were encouraged, but not required, to adopt BRSR
  • FY2022–23 onwards: Mandatory phase — BRSR became a compulsory annual disclosure obligation for the same cohort

Who Must File?23
Under the amended LODR Regulations, the top 1,000 listed entities by market capitalisation are required to submit BRSR annually, starting from FY2022–23. The list of applicable companies is determined based on market capitalisation as of March 31 of the preceding financial year, introducing a dynamic element — companies moving in and out of the top 1,000 threshold will correspondingly enter or exit the mandatory disclosure obligation.

For FY2025–26, SEBI has reiterated that the top 1,000 listed entities by market capitalization remain obligated to file BRSR, with top 500 listed entities specifically required to obtain assessment or assurance of BRSR Core disclosures.

  • Unlisted companies are not currently required to file BRSR, regardless of size, unless they are captured within the consolidated reporting boundary of a listed parent
  • Subsidiaries of listed companies may be included within the reporting boundary if the parent opts for consolidated reporting
  • SME-listed entities are currently excluded, though SEBI has indicated potential future expansion
  • Foreign subsidiaries of Indian listed companies may be included or excluded based on the parent’s chosen reporting boundary

Filing Mechanisms45
The BRSR must be filed as part of the annual report submitted to stock exchanges — typically by June 30, within three months of the financial year-end. Filing must be done in XBRL (eXtensible Business Reporting Language) format on the exchange portals (NSE/BSE NEAPS platforms), along with a PDF version for public viewing.

Structure678
The BRSR framework is organised into three sections:

Section A: General Disclosures
Section A establishes the organisational context within which all subsequent disclosures must be read. It functions as the foundational layer. Key disclosures include:

  • Company details: Name, Corporate Identification Number (CIN), registered office address, website, stock exchange listings, and the contact details of the BRSR designated officer — a requirement that enhances accountability by attaching a human name to the disclosure
  • Reporting boundary: Whether the report is prepared on a standalone or consolidated basis, and a clear explanation of what is included or excluded from scope
  • Business activities: Products and services contributing to 90% of the company’s turnover, along with individual percentage contributions — providing investors a clear map of what the company actually does
  • Markets served: Domestic and international presence, including export revenue as a percentage of total revenue
  • Employee and worker data: Total headcount broken down by permanent/temporary/contractual categories, gender diversity at the board and Key Management Personnel (KMP) level, and employee turnover trends across three financial years — providing a longitudinal view of workforce dynamics
  • CSR activities: A summary of Corporate Social Responsibility (CSR) initiatives and spending, though specific expenditure percentages are no longer separately required under BRSR, as they are captured in the Companies Act disclosures
  • Complaints and grievances: Any received on matters of responsible business conduct, including status of resolution

Section B: Management and Process Disclosures
This is the governance layer. Disclosures include:

  • Board oversight of ESG: Whether the board has a dedicated committee for sustainability, how frequently ESG topics appear on the board agenda, and whether a director has been designated as the responsible signatory for BRSR
  • Policies and frameworks: The existence, scope, and public availability of policies on human rights, labor standards, environmental protection, anti-corruption, data privacy, and other relevant domains — including whether these policies extend to value chain partners
  • Risk management integration: Whether ESG risks are formally integrated into the company’s Enterprise Risk Management (ERM) framework — a critical indicator of institutional maturity, as companies that treat ESG as separate from mainstream risk management are typically further behind in their sustainability journey
  • Stakeholder engagement: Formal mechanisms for identifying, mapping, and engaging with material stakeholders — employees, communities, suppliers, customers, investors, regulators, and civil society — including frequency and outcomes of engagement
  • Training and awareness programs: Details of training conducted on responsible business conduct across employee and worker categories
  • Grievance redressal mechanisms: Internal and external channels available to stakeholders to report concerns, and the effectiveness of these mechanisms

Section C: Principle-wise Performance Disclosures
Structured around the nine principles of NGRBC, it comprises both qualitative narratives and quantitative data points expressed in standardised units (kWh, tonnes of CO₂e, kiloliters, etc.). Each principle contains Essential Indicators (mandatory, 98) and Leadership Indicators (voluntary, 42). The tiered structure is strategically important for sectors with vastly different ESG profiles. A coal mining company and a software services firm face fundamentally different materiality landscapes; the essential indicators ensure a universal baseline while leadership indicators allow sector-specific differentiation.

The nine principles of the National Guidelines on Responsible Business Conduct (NGRBC)910
Table:

#Full NGRBC Statement
P1Businesses should conduct and govern themselves with integrity, and in a manner that is ethical, transparent, and accountable ​
P2Businesses should provide goods and services in a manner that is sustainable and safe ​
P3Businesses should respect and promote the well-being of all employees, including those in their value chains ​
P4Businesses should respect the interests of and be responsive to all their stakeholders ​
P5Businesses should respect and promote human rights ​
P6Businesses should respect and make efforts to protect and restore the environment ​
P7Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent​
P8Businesses should promote inclusive growth and equitable development ​
P9Businesses should engage with and provide value to their consumers in a responsible manner​
  • No principle can be reported on in isolation — SEBI and MCA both emphasize that they are interdependent, interrelated, and must be addressed holistically across a company’s operations and value chain.
  • Environmental disclosures are concentrated almost entirely in P6. Social obligations are distributed across P3, P4, P5, P8, and P9. Governance is embedded in P1, P7, and cuts across all nine through the Section B process disclosures.
  • Essential Indicators constitute the mandatory minimum disclosure requirement. These indicators are designed to be measurable, standardized, and verifiable, reducing the scope for narrative manipulation or selective disclosure.
  • Leadership Indicators represent best-practice and advanced-stage sustainability performance. They allow genuine sustainability leaders to differentiate themselves meaningfully from laggards, and they function as a forward-looking indicator of regulatory direction.

While Section C establishes the full ESG performance architecture, SEBI later identified a narrower subset of metrics that investors consistently relied upon — this became BRSR Core.

BRSR Core1112
In July 2023, SEBI introduced the BRSR Core which is a focused subset of the most material, investor-relevant, and comparable ESG indicators within the broader BRSR. The BRSR Core comprises nine Key Performance Indicators (KPIs) organized across three ESG domains:

Environmental KPIs:

  1. GHG Footprint (Scope 1 and 2 emissions, with PPP-adjusted intensity ratios)
  2. Water Footprint (consumption and intensity)
  3. Energy Footprint (consumption and intensity)
  4. Waste Management (generation, recycling, disposal ratios)

Social KPIs:

  1. Employee Well-Being and Safety (health benefits, accident rates, training metrics)
  2. Gender Diversity in Business (gender representation across levels, pay gap disclosures, POSH complaints)
  3. Enabling Inclusive Development (MSME procurement percentages, local sourcing)

Governance KPIs:

  1. Fairness in Engaging with Customers and Suppliers (cybersecurity incidents, data privacy compliance, supplier payment terms)
  2. Open-ness of Business (corporate governance disclosures, financial transparency indicators)

New KPIs introduced through March 2025 amendments include: job creation in small townsopenness of business metrics, and gross wages paid to women — reflecting SEBI’s intent to deepen the social dimension of BRSR Core.

The BRSR Core is not being rolled out uniformly across all 1,000 companies simultaneously. SEBI has adopted a company-size-stratified phased approach:

Financial YearBRSR Core Applicability
FY 2023–24Top 150 listed entities by market cap
FY 2024–25Top 250 listed entities
FY 2025–26Top 500 listed entities
FY 2026–27Top 1,000 listed entities

This graduated expansion gives smaller companies within the top 1,000 additional preparation time while ensuring that the largest, most systemically important companies are subject to the most rigorous standards first.

Value Chain ESG Disclosures51213
SEBI recognises that for many industries, Scope 3 emissions (those embedded in purchased goods, logistics, and sold products) can represent 70–90% of total carbon footprint; excluding the value chain from sustainability reporting would render BRSR’s environmental data structurally incomplete. However, to ease implementation timelines, SEBI significantly revised the value chain disclosure framework through its March 28, 2025 circular, because many small and mid-size suppliers in Indian value chains are not yet equipped for formal ESG data reporting.​

  • The value chain definition now explicitly covers upstream and downstream partners that individually contribute at least 2% of the listed entity’s total purchases or sales by value — a more precise and operationally workable threshold than the earlier reference to “top 10 suppliers and customers”
  • Companies may limit aggregate disclosures to partners covering 75% of total purchases and sales, providing a practical ceiling that prevents the exercise from becoming an administrative marathon
  • The applicable timeline is:
Financial YearValue Chain Disclosure Requirement
FY 2025–26Voluntary ESG disclosures for top 250 entities; prior year data voluntary
FY 2026–27Voluntary assessment or assurance on value chain ESG disclosures

The shift from a comply-or-explain to a voluntary approach for FY2025–26 reflects SEBI’s responsiveness to industry feedback about implementation readiness — many small and mid-size suppliers in Indian value chains are not yet equipped for formal ESG data reporting.

Assurance Requirements12
When BRSR Core was introduced in July 2023, SEBI mandated reasonable assurance on BRSR Core disclosures in a phased manner. Reasonable assurance — the highest standard of verification in auditing practice — was considered the gold standard for ESG credibility, but proved operationally challenging given the nascent state of sustainability auditing in India.

In response to an Expert Committee recommendation, SEBI made a significant policy adjustment: through the March 2025 circular, the term “assurance” was replaced with “assessment or assurance” for BRSR Core verification. It means listed entities can now choose between:

  • Formal Assurance: Conducted by chartered accountants or statutory auditors following established auditing standards, providing a high degree of confidence in data accuracy
  • Assessment: A broader, potentially profession-agnostic verification process developed per standards by the Industry Standards Forum (ISF) in consultation with SEBI — designed to reduce compliance costs and open the market to qualified non-auditor sustainability practitioners

SEBI has specified that assessors and assurers must meet independence requirements — they cannot be entities that sell products to or offer consulting services to the reporting company. 

The scope of assessment or assurance covers:

  • Accuracy of data reported in BRSR Core KPIs
  • Completeness of disclosures — are all required data points present?
  • Consistency with source documents — does reported data align with underlying records?
  • Compliance with BRSR format — are prescribed units, taxonomies, and templates used correctly?

Industry Standards on BRSR Core2
The December 20, 2024 circular introduced the Industry Standards on Reporting of BRSR Core, developed by the Industry Standards Forum (ISF) — a joint initiative of ASSOCHAM, FICCI, and CII (India’s three premier industry bodies). These standards are not legally binding but are strongly recommended by SEBI and are expected to become the de facto interpretation guide for listed entities and their assurance providers.

Key Provisions:

  1. PPP-Adjusted Intensity Ratios: Companies must report environmental intensity metrics (GHG, energy, water, waste) per unit of revenue, with revenue figures adjusted for Purchasing Power Parity (PPP) using the latest IMF-published conversion rate for India. The same PPP rate must be applied consistently to both the current and prior year comparatives — preventing companies from manipulating apparent year-over-year improvement by switching conversion rates. This PPP adjustment is intended to facilitate meaningful comparison between Indian companies and global peers on investor dashboards.
  2. Output-Based Intensity for Manufacturing: For manufacturing entities, output-based intensity ratios (e.g., tonnes of CO₂e per tonne of production) are required alongside revenue-based metrics. Service entities use Full-Time Equivalents (FTEs) as their input measure. This dual approach acknowledges that revenue-based intensity can be distorted by price fluctuations — a company’s emissions profile doesn’t change just because commodity prices spiked.
  3. Spend-Based Estimation: Where primary measurement data is unavailable for emissions, energy, or water consumption, companies may temporarily use a spend-based approach — estimating environmental footprints based on annual expenditure data and published emission/consumption factors. This provides an entry point for smaller or less-instrumented companies while setting expectations that primary measurement will be established over time.
  4. Greenhouse Gas Emission Factors: For Scope 2 emissions from purchased electricity, companies must use the latest grid emission factor published by the Central Electricity Authority (CEA). Companies using renewable energy certificates (RECs) or power purchase agreements (PPAs) for green power must clearly specify the accounting methodology.
  5. Attribute-wise Technical Clarifications: The standards provide detailed technical guidance on each of the nine BRSR Core attributes.
  6. Global Framework Alignment: The Industry Standards explicitly reference GRI (Global Reporting Initiative), SASB (Sustainability Accounting Standards Board), and TCFD (Task Force on Climate-related Financial Disclosures), establishing conceptual bridges between BRSR and the global sustainability reporting landscape. Companies that already report under these frameworks can leverage their existing infrastructure rather than building parallel reporting systems.

Common Reporting Errors13
In May 2024, SEBI’s Expert Committee issued a report identifying systemic quality failures in BRSR submissions. The most frequently identified problems included:

  • Incorrect units: Reporting energy consumption in megawatts (a measure of power capacity) instead of kilowatt-hours (a measure of energy consumed) — a fundamental error that renders the data meaningless
  • Mathematical inconsistencies: Reporting waste recovered as greater than total waste generated — an arithmetically impossible outcome that signals either poor data governance or deliberate inflation of recycling figures
  • Unexplained zero disclosures: Reporting zero renewable energy without explanation, particularly for large industrial companies where this is implausible
  • Headcount mismatches: Total employees reported differently across different sections of the same report — suggesting that data is being pulled from multiple, unreconciled sources
  • Training overreporting: Training hours provided to more workers than the company’s total worker strength — again, an arithmetically impossible outcome
  • Poor quality environmental data under Principle 6: Generic, unsubstantiated figures for energy and emissions that are clearly not grounded in actual metering or operational data

SEBI’s response to these failures was to require:

  • Internal verification protocols before submission, with the responsible director confirming accuracy
  • Consistent use of prescribed units throughout the report
  • Cross-referencing of BRSR data with corresponding data in audited financial statements and directors’ reports
  • Documented explanations for any “Not Applicable” responses — a blanket N/A without justification is no longer acceptable

Cross-Referencing with Global ESG Frameworks2
Companies that already produce GRI- or TCFD-aligned reports — typically multinationals or companies with significant international investor bases — can provide a mapping table (cross-walk) showing how their existing disclosures satisfy BRSR requirements. This avoids duplication of effort and leverages existing reporting infrastructure. 

It’s also important because with the alphabet soup of sustainability reports plaguing ESG reporting, it’s the right step to not view BRSR as a competing or isolated framework but as part of a convergent global sustainability reporting architecture.

Final points:

  1. BRSR is less about sustainability storytelling and more about data discipline.
    And discipline, in capital markets, compounds.
  2. BRSR positions India as one of the few emerging markets with regulator-mandated ESG reporting, ahead of many developed jurisdictions in structured ESG disclosures.

Sources

  1. BRSR: SEBI Should Make Reporting of Scope 3 Emissions Mandatory for Top 1,000 Listed Firms
  2. BRSR Reporting in India: Key Changes to ESG Disclosures Introduced by SEBI
  3. SEBI Updates BRSR & BRSR Core Compliance for FY 2025–26
  4. NSE Circular on Common Errors in BRSR Submissions (May 2024)
  5. Comprehensive Guide to Filing the Business Responsibility and Sustainability Report (BRSR)
  6. BRSR Principles
  7. Business Responsibility and Sustainability Reporting (BRSR) — CEF Explains
  8. BRSR: A Comprehensive Framework for ESG Disclosure (Company Secretary Journal, May 2024)
  9. Principles Guiding India’s Sustainability Reporting Under BRSR
  10. BRSR 9 Principles: Exploring the Foundations of Accountability
  11. BRSR Core — Framework for Assurance and ESG Disclosures for Value Chain (July 2023)
  12. SEBI Update — ESG Disclosures, BRSR Core Assessment/Assurance and Green Credit Disclosures
  13. BRSR Recommendations by the Expert Committee for Facilitating Ease of Doing Business (May 2024)


Bedfellows with the Taliban: cricket beds down with terrorists

One day, a young Talib beat Laila with a radio antenna. When he was done, he gave a final whack to the back of her neck and said, “I see you again, I’ll beat you until your mother’s milk leaks out of your bones.” – A passage from the novel A Thousand Splendid Suns by Khaled Hosseini, which describes the lives of two fictional Afghan women.1

While the above quote is said to a fictional woman in a novel, the reality is that in just the past 12 months, Afghanistan’s Taliban government has:
1. Codified 35 restrictive articles banning women’s voices in public, requiring full Arabic-style hijab, and prohibiting depiction of humans or animals in media. Women may not travel, study, or appear in public spaces without a male guardian (mahram).​2
2. Mandated that women adopt “Arabic hijab style” within five days, with imprisonment for violators. Families are held responsible for non-compliance.3
3. Prohibited women from entering three district parks, extending the preexisting national ban.3
4. Criminalised women speaking or singing audibly in public, across broadcast and real-life settings.4
5. Prohibited women from afternoon medical visits without male accompaniment, severely restricting access to care in provinces like Badakhshan.5
6. Authorised arrests of women and men for “moral corruption”; 38 arrests reported in nine provinces.6
7. Expelled all female medical students from health training colleges nationwide.7
8. Prohibited shopkeepers from talking to female customers in Takhar and Nangarhar provinces to “protect modesty”.8
9. Ordered women to block home windows to avoid being seen by neighbors.9
10. Blocked Hazara-led religious ceremonies in Bamyan and Daykundi Provinces ahead of Ashura.10
11. Facilitated dispossession of Hazara farmlands for Kuchi nomads under “historic restitution” justifications; over 25,000 displaced in 2024–25.11
12. Diverted international rations away from Hazara-majority central highlands to Pashtun-controlled areas.11
13. Marginalised Shia observances by defining “permissible Islamic behavior” under Sunni Hanafi doctrines.12

In all, in the past few months, Afghanistan’s Taliban government has entrenched a dual system of apartheid– gender and sectarian- now recognised by experts as constituting crimes against humanity and genocide risk indicators according to the UN and Human Rights Watch.​

And yet, cricket remains nearly entirely silent.

ICC’s policy on political intervention in cricket
The International Cricket Council (ICC) is cricket’s international governing body. It claims to uphold the autonomy of cricket via its official policy, which prohibits political appointments and undue government interference in the administration of national cricket boards, favouring free elections and board independence,13 and they can suspend a country’s membership for government meddling, with bans or warnings applied until compliance is restored.14

Here are some recent examples of this policy in action:

  • Zimbabwe (2019): The ICC suspended Zimbabwe Cricket for failing to ensure no government interference in its cricket administration, barring their teams from ICC events until the suspension was lifted.15
  • Sri Lanka (2024): Sri Lanka Cricket was suspended by the ICC due to evidence of government interference, including the sacking of board officials and attempts at regulatory control.16 

The South Africa Precedent
One does wonder what the difference is between apartheid South Africa, and present-day Afghanistan in ICC’s eyes. ​

In 1970, the ICC banned South Africa from international cricket due to racial apartheid policies that prevented non-white players from representing the national team and subjected touring players of color to discriminatory treatment.1718 This ban remained in effect for 21 years, until Nelson Mandela’s release and the dismantling of apartheid in 1991.1718

The ICC maintained the ban despite South Africa’s 1976 attempt to desegregate cricket through the formation of a non-racial governing body, the South African Cricket Union.1718 Only after apartheid’s complete dismantling and at the personal request of Nelson Mandela was South Africa readmitted to the ICC and Test cricket in 1991.17

Here’s a comparison of the actions of the Taliban government in Afghanistan with those of some other comparable governments:

CategoryTaliban Afghanistan (2024–2025)Apartheid South Africa (1948–1991)Nazi Germany (1933–1945)Myanmar Junta vs Rohingya (2016–Present)
Basis of OppressionGender, ethnicity, and religion (women, Hazaras, Shia, Tajiks)Race and ethnicity (Black Africans, Coloureds, Indians)Race and religion (Jews, Roma, disabled)1819Ethnicity and religion (Rohingya Muslims)2326
Right to EducationTotal ban on women and girls attending secondary and tertiary institutionsSegregated and inferior “Bantu Education Act” (1953)Jews banned from universities (1933–1938)2021Rohingya schools closed or destroyed2728
Employment RestrictionsWomen banned from most occupations; Hazara excluded from government postsNon‑whites restricted to menial labourJews removed from public service (1933)21Rohingya barred from public sector roles2930
Freedom of MovementWomen require male guardian; Hazaras displaced from ancestral landsPass laws required for Black movement across provincesJews prohibited from using public transport (1941)2223Rohingya confined to internment camps3132
Legal SystemShia and women excluded; Taliban enforces Hanafi systemSeparate, racially biased courts; no franchise for non‑whitesNuremberg Laws stripped Jews of citizenship (1935)24No legal recourse for Rohingya abuses3334
Violence and AtrocitiesTargeted killings, sexual violence, execution of Hazara protestorsPolice brutality, executions, detentionsHolocaust: extermination camps, 6 million Jews killed242017–present killings, over 700,000 displaced3536
Cultural ErasureDestruction of Hazara monuments; ban on female voices and presenceSuppression of African culture and languagesBook burnings, bans on Jewish culture25Destruction of mosques and Rohingya villages3738
International ResponseLimited sanctions, ICC charges for gender persecutionUN boycott and sports sanctions, 1970–1991Nuremberg Trials post‑WWII20ICC genocide probe, UN sanctions on Myanmar3940
ClassificationGender apartheid & ethnic persecutionRacial apartheidGenocide [UN 1948]19Genocide [UN Fact‑Finding Mission 2018]3941
Apparently not an apartheid according to the powers that be in Cricket

Negotiating with terrorists
It’s evident that the ICC believes in being gentle with cricket’s resident terrorists. In April 2025, the ICC confirmed it would not cut funding to the Afghanistan Cricket Board and would instead “pursue dialogue and constructive engagement”.42 An ICC spokesperson told Sky News: “We are committed to leveraging our influence constructively to support the Afghanistan Cricket Board in fostering cricket development and ensuring playing opportunities for both men and women in Afghanistan”.43

Naturally, this approach has yielded no progress.

The India Connection
I believe India’s geopolitics is directly shaping the ICC’s approach to Afghanistan, a pattern evident across multiple recent ICC decisions.

India is responsible for a large part of the ICC’s global revenue,44 primarily through the BCCI and the massive domestic cricket market, and Jay Shah, the son of Indian Home Minister Amit Shah, was elected unopposed as ICC chairman in December 2024, after serving as BCCI secretary and Asian Cricket Council chief.45 India has helped build Afghanistan’s cricketing infrastructure, provided technical training, hosted Afghan teams, funded stadiums, and arranged commercial sponsorships.46

While India does not formally recognise the Taliban government in Afghanistan,47 it (we the citizens, our elected politicians) have adopted a policy of “engagement without recognition.”4849 This means India maintains working diplomatic and economic relations with the Taliban regime, while refraining from granting it official, de jure legitimacy.49 We engage with the Taliban government as the de facto authority in Kabul for practical and strategic reasons, therefore granting it legitimacy.

India’s activities in Afghanistan under the Taliban include diplomatic representation, large-scale humanitarian aid, development assistance, and ongoing political dialogue, especially to safeguard its security and regional interests.50 This approach mirrors India’s policies towards other regimes like the Myanmar junta and Taiwan: open channels for practical coordination, yet withholding formal recognition, consistent with international law on diplomatic relations.5152

​However, In October 2025, following the visit of Taliban Foreign Minister Amir Khan Muttaqi to New Delhi, India announced the upgrading of its technical mission in Kabul to a full embassy, a clear sign of deepening engagement, despite the absence of formal recognition.53

At this point, please also note that I do understand that sanctions against Afghanistan would be less effective than those against apartheid South Africa because the Taliban government, unlike South Africa’s white minority regime, does not depend on international legitimacy or economic integration with cricket-playing nations, and yet if India cared about the girls, women and minorities being oppressed in Afghanistan, they would be banned from cricket.

But India needs a counterweight to Pakistani terrorism against India. Afghanistan under the Taliban serves as a strategic buffer and potential ally in India’s regional security calculations,54 and the Afghan women and minorities are simply not part of the consideration. And as we know, India’s power has affected ICC’s decisions previously.555657

What’s happening right now
Australia remains the only country in cricket that has taken a stand on the matter by refusing to play bilateral matches, citing deep discomfort with the Taliban regime’s escalating crackdown on women’s rights and participation in sport. Since 2021, Cricket Australia has cancelled multiple series, most recently a T20 fixture in 2025.5859

Australia also hosts exiled women cricketers from Afghanistan, such as Benafsha Hashimi and Firooza Amiri, the latter of whom has pleaded that the ICC doesn’t even need to ban the Afghanistan men’s team: “Don’t ban the Afghanistan men’s side from playing international cricket but do expect them to do more for the women and girls who don’t have the same rights they do,” Amiri told ESPN, once again underlining cricket’s silence.60

In March 2025, Human Rights Watch addressed an open letter to ICC Chair Jay Shah, urging the council to suspend Afghanistan’s membership until women and girls regain access to education and sport. Minky Worden, HRW’s Director of Global Initiatives, argued that the ICC’s permissiveness “places it on the side of the Taliban, not the women cricketers in exile”.61

Human Rights Watch and several national cricket boards, including the England and Wales Cricket Board (ECB), have pressed the ICC to adopt a formal human rights policy aligned with UN principles, similar to frameworks now required by the International Olympic Committee (IOC).62 The IOC previously suspended Afghanistan’s Olympic Committee in 1999 for barring female athletes- an exact parallel to today’s situation.

Publicly, the council maintains support for the displaced Afghan women cricketers in exile but has stopped short of recognition or reallocation of resources to them.63 In April 2025, the ICC announced a separate initiative to support displaced Afghan women cricketers through a task force partnering with Cricket Australia, the England and Wales Cricket Board, and the Board of Control for Cricket in India.64 Critically, however, this new funding stream does not reduce or redirect any money from the ACB- the board responsible for excluding women continues to receive full funding.65

As of 2025, the ICC continues to provide the Afghanistan Cricket Board (ACB) with approximately $17 million USD (£13 million) in annual funding, exclusively allocated to men’s cricket.66 This funding persists even as Afghanistan remains the only ICC full member without a women’s team.

Meanwhile, while the International Cricket Council continues to sleep on their job, 2.2 million girls remain banned from school and university education indefinitely.67

NB: I’m not expecting this to make any institutional changes. I’m not expecting any difference in the state of the suffering Afghans. I have no hope of anything getting better. I even understand the geopolitics and the realpolitik behind the Indian Government’s engagement with the terrorists- they’re trying to choose fewer terrorism deaths for Indians over people they are not morally responsible for. I’m writing because I’m exhausted. I’m tired of women paying the price and men absconding responsibility, even traveling the world playing goddamn cricket with impunity while at it. And I’m writing because who else will? The terrorised Afghans certainly cannot. The exiled Afghan cricketers can barely speak out even in a supposedly safe nation like Australia. But perhaps one day this piece may serve as the evidence that people knew what was happening, or even just show those who suffered that we saw them. You were not erased, my sisters.

Sources

  1. A Thousand Splendid Suns Quotes With Page Numbers
  2. Afghanistan: An update on the Taliban’s new “Morality law”
  3. Tracking the Taliban’s (Mis)Treatment of Women
  4. BBC News – Taliban bans women’s voices in public media spaces
  5. UNAMA – Moral Oversight Report: Impacts on Afghan Women (PDF)
  6. USCIRF – 2025 Issue Update: Afghanistan Morality Law
  7. The Lancet – Taliban expels female medical students from Afghan colleges
  8. Human Rights Watch – World Report 2025: Afghanistan
  9. Le Monde – Taliban assault on women’s rights reaches new level
  10. Kabul Now – Taliban blocks planned Shia religious gathering
  11. Minority Rights Group – Hazaras 2025: Ongoing persecution and displacement
  12. Jurist – Violence and Exclusion of Hazaras and Shias under Taliban Rule
  13. ESPNcricinfo – ICC reviewing stance against government interference
  14. Cricbuzz – ICC bans political interference in cricket
  15. BBC Sport – ICC suspends Zimbabwe over political meddling
  16. Church Court Chambers – Why the ICC suspended Sri Lanka Cricket
  17. ESPNcricinfo – Cricket’s Turning Points: South Africa are isolated
  18. Dawn – South Africa uniquely placed as a cricketing nation
  19. Anne Frank House – What is the Holocaust?
  20. Holocaust Memorial Day Trust – Nazi Persecution of the Jews
  21. Holocaust Museum Houston – Anti-Jewish Legislation Research Guide
  22. U.S. National Archives – The Nuremberg Laws
  23. Holocaust Encyclopedia – The Nuremberg Race Laws
  24. Holocaust Encyclopedia – The Nuremberg Race Laws
  25. Holocaust Memorial Day Trust – Nazi Persecution of the Jews
  26. Council on Foreign Relations – What Forces Are Fueling Myanmar’s Rohingya Crisis?
  27. Al Jazeera – Rohingya facing “lost generation” of children out of school
  28. Oxford Human Rights Hub – The Elusive Right to Education for the Rohingya People
  29. Nature – Poverty and Precarious Employment: The Case of Rohingya Refugees
  30. Frontiers in Political Science – Statelessness of an Ethnic Minority: The Case of Rohingya
  31. Fortify Rights – UN Security Council: Refer Mass Internment of Muslims in Myanmar to ICC
  32. Al Jazeera – Myanmar’s Military Coup Prolongs Misery for Rohingya
  33. UK Home Office – Myanmar: Rohingya (including Rohingya in Bangladesh)
  34. OHCHR – Myanmar Authorities Must Ensure Full Legal Recognition of Citizenship Rights
  35. UN OHCHR – Report of the Independent International Fact-Finding Mission on Myanmar (PDF)
  36. Human Rights Watch – No Justice, No Freedom for Rohingya: Five Years On
  37. Human Rights Watch – Burma: Scores of Rohingya Villages Bulldozed
  38. Anadolu Agency – UN Investigative Body Finds Rohingya Villages Destroyed, Land Seized
  39. UN IIMM – Situation of Bangladesh / Myanmar (ICC Documentation Page)
  40. Al Jazeera – ICC Prosecutor Seeks Arrest Warrant for Myanmar Military Regime Chief
  41. Columbia Journal of Transnational Law – Three Avenues to Justice for the Rohingya
  42. ICC – Provides Update on Displaced Afghan Women Cricketers Initiative
  43. ICC – Announces Initiative to Support Afghan Women Cricketers
  44. ESPNcricinfo – BCCI Set to Get Nearly 40% of ICC’s Annual Revenue Share
  45. ICC – Jay Shah Elected Unopposed as Independent Chair of ICC
  46. Sputnik News – How India Has Contributed to Afghanistan’s Rise in Cricket
  47. Hindustan Times – India Formally Upgrades Technical Mission in Kabul to Embassy
  48. ICWA – India’s First Ministerial Engagement with the Taliban
  49. Indian Express – Engagement Without Recognition: Decoding India’s Taliban Policy
  50. Reuters – India to Reopen Its Embassy in Kabul
  51. South China Morning Post – India’s Myanmar Diplomacy Imperils ASEAN’s Peace Process
  52. Carnegie Endowment for International Peace – The Case for a Pragmatic India-Taiwan Partnership
  53. Times of India – India Reopens Kabul Embassy; Full Mission Returns After Four Years
  54. Al Jazeera – Afghan Foreign Minister in India: Why New Delhi Is Embracing the Taliban Now
  55. NDTV Sports – Champions Trophy Hybrid Model ‘Finalised’, Says Report
  56. Cricbuzz – CT 2025: PCB choose UAE as neutral venue for India games
  57. Business Standard – Asia Cup 2023 to be held in Hybrid Model from August 31st to September 17
  58. Al Jazeera – Cricket Australia Defends Afghanistan Boycott After ‘Hypocrisy’ Accusations
  59. SuperSport – Cricket Australia Defends Afghanistan Boycott Stance
  60. ESPNcricinfo – Exiled Afghanistan Women Players Urge Men’s Team to ‘Be the Voice of the Girls’
  61. ESPNcricinfo – Human Rights Watch Asks ICC to Suspend Afghanistan’s Membership
  62. Cricbuzz – ICC Urged to Take Action on Women’s Cricket in Afghanistan
  63. DW – Cricket: Afghanistan Women’s History Is Starting Again
  64. ABC News Australia – ICC Plan for Afghan Women’s Cricket Team “Exciting but Unclear”
  65. Cricket Australia – ICC Establishes Support Fund for Displaced Afghan Women’s Cricketers
  66. Forbes – Funding Set for Displaced Afghan Women Cricketers, but Questions Remain
  67. UNESCO – Afghanistan: Four Years On, 2.2 Million Girls Still Banned from School

How does MRF decide whose bat to sponsor?

MRF, originally Madras Rubber Factory, started as a balloon manufacturer and grew into India’s largest tyre company. Over the years, the group diversified into sporting goods, with active involvement in cricket kits, bats, gloves, and a significant marketing footprint in Indian and, to a limited extent, global sporting culture.1 Over time their bat sponsorship has come to represent a potential enthronement, if not outright coronation of the Indian cricket’s next king. It’s fairly entertaining that MRF, once just a tyre company, now doubles as a premium sporting label—with 350+ retail outlets across India as of 2025.2

I’ve wondered about how MRF chooses, or chooses not to, sponsor someone’s bat, especially since their quick switch to sponsor Shubman Gill’s bat. And yet, the selection is not quite destiny: of the 11 players who have carried an MRF bat, 5 were asked to return it. That’s a 45% failure rate.

Also, two things: 1. The tables are pictures because I’m not mucking about with WordPress tables with this much data. It’s an absurdity. 2. I’ve done my best to check the age figures since it was relevant to this post, but I haven’t checked the cricket stats much.

The Cricketers
Sachin Tendulkar (India)
Brian Lara (WI),
Steve Waugh (Australia),
Gautam Gambhir (India)
Rohit Sharma (India)
Virat Kohli (India),
Sanju Samson (India),
Shikhar Dhawan (India),
AB de Villiers (SA),
Prithvi Shaw (India),
Mignon du Preez (SA),3
Shubman Gill (India)

The Logic
There is clearly a statistical basis for screening the candidates. Each of the cricketers finally offered the bat had a highly successful year 3 years before they got the sponsorship call. The first mottle appears two years before the sponsorship is offered, with Rohit Sharma not quite having a year to remember. One year before the sponsorship, performances from Rohit Sharma and Gautam Gambhir started fading. They were still offered sponsorships, though, so MRF was willing to bet they would pick up, and also be culturally relevant in the future.

Word on the cricketing streets is that MRF spots its talents early in their career, but the average age at the beginning of player sponsorships comes out to be 26.67, with Prithvi Shaw being the earliest pick at 17 (or 18) years old, and Steve Waugh the senior most at 36. Removing these outliers returns an average age of… 26.67 years, and removing anyone who was sponsored before 2010 makes for an average of 25.38 years.

Age of MRF bat sponsorees at the beginning and end of their tenures

It’s obvious that the original three foreign icons (Lara, Waugh, AB) were established greats when they got the MRF deal; the rest, especially Indian batters, were mostly in their 20s. Given that batters usually come into their own around 27-29 (my personal opinion), and can certainly be prodigious well into the 30s, this is consistent with MRF’s search for the next (Indian) batting legend. To be noted, all the averages tallied above fall around or before the age of 27.

These are the statistical inputs I’ve been able to spot for the champaigne:

  • Insatiability, 850–1,200+ runs/year in Tests or ODIs for at least one of the years before signing.
  • Consistent 100s in decisive or pressure games (World Cups, series deciders).
  • ICC event hundreds and being among top run scorers seems to be a trademark.
  • Youth milestones and early leadership (U19 or domestic tournament MVPs- Kohli, Dhawan, Gill, and Shaw were all U19 heroes)
  • Multi-format prowess, such as hundreds in all formats by 25.
  • Longevity (sustained form) or a steep climb in performance

The Magic
MRF’s track record of signing “the next big thing” is so consistent, it borders on magic:

  • They chose Tendulkar just before he ruled the 90s and 00s.
  • Bet on Virat as he broke records and changed Indian cricket’s mindset.
  • Handed Gill the baton right before a record-shattering run in 2025, including 4 consecutive Test hundreds and a string of 20→100 conversions unparalleled among peers, although this was an obvious signing with Virat retiring right before the series, and Gill now the heir apparent to the Indian No. 4 position, and the Test captain).
  • Timing is critical. MRF’s model aims to find the next star on the rise- locking in ambassadors just as they shift from prodigy to global icon (e.g., Sachin before he became Sachin, Kohli before captaincy explosion).

    MRF therefore seems to filter for improvement arcs, multi-format ability, and brand values- not just averages. But cricketing “auras” also matter- hence Kohli, Gill (not just Indian and prodigious, but also temperamentally dignified, in possession of impressive communication skills, the worlds best ODI batter and other top performances in his age cohort, and the Indian Test captain) over otherwise comparable international stars like Dravid (diluted the Indian audience, not a superstar when compared to Sachin), Kallis (not Indian, and not as popular in India as AB), Sangakkara (see Kallis), Laxman (same as Dravid, but also confined to Tests), MS Dhoni (Not an era defining batter), KL Rahul (beautiful, inconsistent), Yashaswi Jaiswal (incredible story but not as established as Shubman, has not yet shown all format ability, although watch out for this in the future), Rishabh Pant (Likely not considered an era defining batter, but is also Spidey, and that doesn’t fit the brand image), Abhishek Sharma (maybe soon?). Ambassadors are chosen not only for statistics, but also for embodying resilience (Tendulkar’s comebacks), toughness (Kohli’s chases), artistic mastery (Lara’s flair), performance (Dhawan’s ICC tournament performances), or next-gen inspiration (Shaw, Samson, Gill). Jaiswal and Pant’s exclusions highlight that charisma alone isn’t enough- they’re watching form across formats, market potential, and personality fit. Not sponsoring MS indicates they’re not too swayed by long term captaincy or intense fandom or even the number of trophies won as skipper- once again, it’s the batting output that matters.

The Business
MRF’s approach to selecting its bat ambassadors is a nuanced blend of data-driven business strategy, brand vision, and razor-sharp market positioning, refined over decades of cricketing association. India is MRF’s largest tyre and sporting market, and cricket is India’s premier sport. MRF therefore focuses on pan-Indian cricket icons as ambassadors to maximise its cultural and commercial return on investment. This also means that non Indians rarely get the MRF sticker.

A selection of players who were not MRF bat ambassadors, and why I think that was so

By not sponsoring too many players simultaneously- and never directly competing with its own ambassadors for limelight- MRF ensures its bat sticker is always exceptional, not generic. The sustained, highly visible association with generational talents strengthens brand recall far beyond the cricket field- from tyre showrooms to street cricket bats. So concerned is MRF with its bat’s legacy, the company has divided its brand into three- the Genius bat for the artists and prodigies (Tendulkar, Kohli, AB, Gill), the Conqueror bat for those known for their grit (Steve Waugh), and the Wizard bat for Brian Lara.

MRF is always looking a generation ahead. As one ambassador (Tendulkar, Kohli) nears twilight, MRF signs the next rising phenom (Gill over Jaiswal, as the latter had not yet ticked every box), displaying continuity and reducing sponsorship risk, while ensuring ongoing cultural presence, with each transition becoming a media/ marketing event in itself. The brand’s investment is offset by massive earned media (“free” advertising) via on-field heroics, social media virality, and generational recall—no other bat sticker is as instantly recognized in world cricket.

Note: This post earlier included Sir Hadlee, but I’ve not been able to find any credible sources for it, so I’ve removed any mention of him, and redone the calculations.

Sources
1. MRF Ltd. – Fortune India
2. MRF Sports
3. @mdpminx22 on Instagram

Indian MSMEs and ESG

The regulatory landscape for Indian MSMEs has shifted dramatically with the Securities and Exchange Board of India’s (SEBI) Business Responsibility and Sustainability Reporting (BRSR) Core framework. This framework now requires India’s largest listed companies to report not only on their own Environmental, Social, and Governance (ESG) performance but also on the ESG practices of key value chain partners—including MSMEs.1

Scope and Coverage2

  1. Applicability: From FY 2024–25, the BRSR Core value chain disclosure applies to the top 250 listed entities by market capitalization, with phased expansion in subsequent years.
  2. Value Chain Reporting: Companies must report ESG data for their top upstream (suppliers) and downstream (customers) partners that individually account for 2% or more of purchases or sales, or collectively represent at least 75% of total purchases and sales by value.
  3. KPIs: Reporting covers greenhouse gas emissions, energy and water use, circularity, and social factors attributable to the listed company’s business with each value chain partner.
  4. Timeline: Mandatory value chain ESG disclosures begin in FY 2025–26, with third-party assessment or assurance required from FY 2026–27.
  5. This means MSMEs that are part of the supply chains of large corporates must now demonstrate their sustainability credentials—or risk exclusion.

The Business Case for MSMEs Going Green

  1. Continued Access to Large Corporate Supply Chains: With large companies under regulatory pressure to disclose their value chain’s ESG performance, MSMEs unable to provide relevant sustainability data or demonstrate green practices risk being replaced by more compliant competitors.
  2. Market and Export Opportunities: Many global buyers and Indian corporates now require ESG compliance from suppliers. MSMEs with green credentials gain access to new markets, preferred vendor status, and export opportunities, especially as international regulations tighten.
  3. Cost Savings and Efficiency: Adopting green practices—energy efficiency, waste reduction, renewable energy—reduces operational costs and improves margins, directly benefiting the bottom line.
  4. Regulatory Preparedness: MSMEs that align early with BRSR and other ESG frameworks are better positioned for future regulations, including potential carbon taxes, border adjustments, and mandatory disclosures.
  5. Enhanced Reputation and Financing: Demonstrating ESG leadership boosts credibility with customers, investors, and lenders, and can improve access to green finance and government incentives. Companies with strong ESG credentials often enjoy better access to financing and lower costs of capital.

Challenges Hindering MSMEs’ Green Transition3

Despite the clear benefits, MSMEs face significant barriers:

  1. High Upfront Costs: Transitioning to green technologies requires capital, which is often scarce for MSMEs operating on thin margins.
  2. Limited Access to Green Finance: Only about 10% of MSMEs access formal green finance, mainly due to collateral and credit barriers. A third are unaware of major schemes like ZED certification.4
  3. Infrastructure Gaps: Many MSMEs, especially in tier II and III cities, rely on outdated machinery and diesel generators due to unreliable power grids.
  4. Technological and Knowledge Constraints: Lower technological sophistication and lack of awareness about sustainability frameworks impede progress.
  5. Opportunities on the Horizon
  6. Sustainable practices are opening new markets and enhancing credibility, especially for MSMEs in global supply chains where environmental compliance is increasingly mandatory. For example, textile MSMEs in Tiruppur have adopted Zero Liquid Discharge systems to meet stringent European export requirements.

The Numbers4

  1. Solar Adoption: By 2024, 21% of Indian MSMEs were powered by solar energy, and 31% had adopted energy-efficient machinery.
  2. Rooftop Solar: Installations reached 11.87 GW, cutting average power bills by 30% and typically paying for themselves within three to five years.
  3. Emission Reductions: This shift could potentially reduce CO₂ emissions by 110 million tonnes annually.
  4. State Leaders: Textile and chemical industries are leading the transition, with Gujarat, Maharashtra, and Kerala making significant progress, and other states like Uttar Pradesh eager to join the movement.
  5. If this momentum continues, MSMEs could contribute up to 50% of India’s 2030 renewable energy goal—a transformative impact for the nation’s sustainability ambitions.
  6. However, not all numbers are positive: The Government of India launched two schemes to help MSMEs adopt environmentally friendly technology, the MSME GIFT (Green Investment and Financing for Transformation) Scheme, which focuses on supporting MSMEs to adopt clean and green technologies through concessional finance and risk-sharing, and the MSME SPICE (Scheme for Promotion and Investment in Circular Economy), which aims to incentivize MSMEs to implement circular economy practices such as recycling, reuse, and resource efficiency, primarily through capital subsidies. As of December 2024, MSME SPICE had assisted only six MSME accounts, with one reported beneficiary from Ahmednagar, Maharashtra. The total expenditure was ₹1.31 crore out of the ₹472.5 crore budget5… and as for MSME GIFT, as of July 2025, there are no published official numbers from the Ministry of MSME, SIDBI, or other government sources specifying the exact number of MSMEs that have received benefits under the GIFT scheme. The World Bank’s implementation report on the broader RAMP program (which includes GIFT) notes that as of November 2024, the program had disbursed $231 million (about 46% of the total loan) for MSME competitiveness and green technology adoption, but does not break down numbers specifically for GIFT.6

The Road Ahead: From Compliance to Competitive Advantage

The SEBI BRSR Core mandate is more than a compliance requirement; it’s a catalyst for a fundamental shift in how Indian MSMEs operate. Integrating ESG principles is no longer just about risk mitigation—it’s about unlocking new business opportunities, future-proofing operations, and contributing to India’s global climate commitments.

For MSMEs, the message is clear: Going green is not just good for the planet—it’s now essential for business survival and growth.

Sources

  1. BRSR Core – Framework for assurance and ESG disclosures for value chain
  2. SEBI’s Latest ESG Disclosure Reforms: Impact on Indian Businesses and Compliance Strategies
  3. The missing link: Why MSMEs need more than just budgetary support for green growth
  4. Sustainable development: The rise of green MSMEs
  5. MSE-SPICE Scheme
  6. Raising and Accelerating MSME Performance (P172226)

A guide to India’s legal framework for ESG

ESG stands for Environmental, Social, and Governance. ESG investing evaluates companies on non financial factors covered under any of these three categories. While many issues are multifaceted and may fall under one or more of these headings, the way to differentiate them may lie in separating into the Planet, People, and Profit maxim: E covers all issues that affect the planet, S is for anything affecting humans directly, and G (the most regulated of the three) is for corporate governance issues.

India has a web of laws, regulations, and policies that can be classified as ESG requirements or enablers (now that the acronym ‘ESG’ exists, that is). Here is a run down of some of the most prominent ones (it’s long):

I. Environmental Legal Requirements in India

1. Wildlife (Protection) Act, 1972
This Act provides a legal framework for the protection of wildlife species and their habitats, including the creation of protected areas such as national parks and wildlife sanctuaries. It prohibits hunting and trade in endangered species, and prescribes penalties for violations. The Act also empowers authorities to regulate activities within protected areas to conserve biodiversity.

2. Water (Prevention and Control of Pollution) Act, 1974
The Water Act is designed to prevent and control water pollution and maintain or restore the wholesomeness of water. Section 16 tasks the Central Pollution Control Board with setting standards for the discharge of pollutants into water bodies, monitoring compliance, and coordinating with state boards. The Act provides for the prosecution of violators and the issuance of directives to polluting entities to cease or modify operations.

3. Forest (Conservation) Act, 1980
The Forest (Conservation) Act restricts the diversion of forest land for non-forest purposes without prior approval from the central government. It aims to curb deforestation and promote sustainable forest management by requiring compensatory afforestation and environmental impact assessments for approved projects. The Act also provides for the protection of forest biodiversity and the rights of forest-dwelling communities.

4. Air (Prevention and Control of Pollution) Act, 1981
This Act establishes a regulatory framework for the prevention, control, and abatement of air pollution in India. Section 17 assigns State Pollution Control Boards the responsibility to set air quality standards, monitor emissions from industrial and vehicular sources, and enforce compliance through permits and penalties. The Act empowers authorities to close or restrict operations of polluting industries and to promote cleaner technologies.

5. Environment (Protection) Act, 1986
The Environment (Protection) Act, 1986, is India’s primary legislation for the protection and improvement of the environment. Section 3 of the Act empowers the central government to take all necessary measures to protect and improve environmental quality, prevent and control pollution, and set standards for emissions and discharges. Section 6 authorizes the government to make rules for regulating environmental pollution, covering aspects such as waste management, hazardous substances, and the preservation of ecological balance.

  1. Key Rules under the Environment (Protection) Act:
  • E-Waste (Management) Rules, 2022:
    These rules establish responsibilities for manufacturers, producers, and recyclers of electronic and electrical equipment to ensure environmentally sound management of e-waste. They require the implementation of extended producer responsibility, mandating producers to collect and channel e-waste to authorized dismantlers or recyclers. The amendments in 2018 further tightened collection targets and reporting obligations, aiming to reduce the environmental impact of rapidly growing electronic waste streams.
  • Battery Waste Management Rules, 2022:
    The 2001 rules regulate the collection, processing, and recycling of used batteries to prevent hazardous lead and acid pollution. The Draft Battery Waste Management Rules, 2020, propose stricter norms for battery producers, including mandatory take-back systems and environmentally safe recycling processes. These provisions are designed to minimize environmental contamination and promote circular economy practices in the battery industry.
  • Bio-Medical Waste Management Rules, 2016:
    These rules provide a framework for the safe handling, segregation, transport, treatment, and disposal of biomedical waste generated by healthcare facilities. They impose strict requirements on hospitals and clinics to ensure that infectious and hazardous waste does not contaminate the environment or pose health risks to the public. Compliance is enforced through regular audits and penalties for violations.
  • Plastic Waste Management Rules, 2016, 2021, 2022:
    The rules aim to reduce plastic pollution by imposing restrictions on the manufacture, sale, and use of certain single-use plastics. They require producers, importers, and brand owners to implement extended producer responsibility, ensuring that plastic waste is collected and recycled or disposed of in an environmentally friendly manner. Amendments in 2021 and 2022 further expanded the scope of regulated items and tightened compliance timelines. The 2022 notification banned Single Use Plastics (SUPs) with effect from 01.07.2022.
  • Solid Waste Management Rules, 2016:
    These rules set out the responsibilities of municipal authorities and other stakeholders for the segregation, collection, processing, and disposal of solid waste. They emphasize the need for source segregation of biodegradable and non-biodegradable waste, and promote composting, recycling, and waste-to-energy initiatives. The rules also mandate the inclusion of informal waste pickers into the formal waste management system.
  • Construction and Demolition Waste Management Rules, 2016:
    The rules require generators of construction and demolition waste to segregate and store waste at source, and ensure its safe transportation to recycling facilities. They promote the recycling and reuse of debris, reducing the burden on landfills and conserving natural resources. Local authorities are tasked with establishing collection centres and monitoring compliance.
  • Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 (amended 2019):
    These rules regulate the generation, handling, storage, transportation, and disposal of hazardous wastes, including their import and export. They mandate that hazardous waste be handled only by authorized operators and in accordance with prescribed safety standards. Amendments in 2019 strengthened provisions for tracking and reporting waste movements, and aligned Indian regulations with international conventions.
  • Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989:
    These rules govern the safe manufacture, storage, and import of hazardous chemicals, requiring companies to undertake risk assessments and prepare on-site and off-site emergency plans. Facilities must notify authorities about the quantities and types of hazardous chemicals handled, and are subject to regular inspections. The aim is to prevent industrial accidents and minimize risks to workers and the surrounding community.
  • Coastal Regulation Zone Notification, 2019; related 2021 procedures:
    The notification demarcates coastal regulation zones and restricts certain activities to protect sensitive coastal ecosystems. It sets out guidelines for permissible development, conservation of mangroves, and protection of traditional fishing communities. The 2021 procedures clarify compliance requirements and streamline the approval process for coastal projects.
  • Environment Impact Assessment (EIA) Notification, 2006 (and amendments):
    The EIA Notification requires prior environmental clearance for specified categories of projects, based on a detailed assessment of their potential impacts. It mandates public consultations, expert appraisal, and periodic monitoring to ensure compliance with environmental safeguards. Amendments over the years have sought to balance developmental needs with environmental protection by refining project categories and timelines. A draft considered controversial was tabled in 2020 which is still under review, and nothing major has been finalised as of writing this.

6. Public Liability Insurance Act, 1991
This Act requires owners handling hazardous substances to take out insurance policies to provide immediate relief to victims of accidents. It ensures that compensation is available for injury, death, or property damage resulting from hazardous activities, regardless of fault. The Act also establishes an Environmental Relief Fund to support compensation payments.

7. Energy Conservation Act 2001 (amended 2022)
The original Energy Conservation Act, 2001 established the Bureau of Energy Efficiency (BEE) and set norms for energy efficiency in appliances, buildings, and large energy consumers. The 2022 amendment (which came into effect on 01.01.2023), establishes a legal basis for a carbon market, mandates non-fossil energy use by designated users, expands efficiency standards, and updates building codes.

8. Biological Diversity Act, 2002
The Biological Diversity Act promotes the conservation of India’s biological diversity and the sustainable use of its components. It establishes mechanisms for equitable sharing of benefits arising from the use of genetic resources, and regulates access to biological resources by domestic and foreign entities. The Act is implemented through the National Biodiversity Authority and State Biodiversity Boards.

9. National Green Tribunal Act, 2010
The National Green Tribunal Act establishes a specialized tribunal for the expeditious resolution of environmental disputes involving multi-disciplinary issues. The Tribunal has the power to provide relief, compensation, and restitution of damaged environments, and its orders are binding. It aims to ensure effective and speedy environmental justice for affected parties.

10. Policies and Schemes

  • Carbon Credit Trading Scheme, 2023
    The Carbon Credit Trading Scheme, 2023, introduces a regulated market for trading carbon credits in India. It enables entities that reduce their greenhouse gas emissions below prescribed targets to sell credits to those exceeding their limits. This market-based mechanism incentivizes emission reductions and supports India’s climate change commitments. This scheme is now operational under the Energy Conservation Act (amended 2022).
  • Green Credit Disclosures (SEBI LODR, BRSR Principle 6)
    From the financial year 2024-25, listed companies are required to disclose the green credits they generate or procure, as well as those of their top-10 value chain partners. This disclosure is part of the Business Responsibility and Sustainability Reporting (BRSR) framework and aims to increase transparency and accountability in corporate environmental performance.
  • Priority Sector Lending for Renewable Energy (RBI Guidelines)
    The Reserve Bank of India’s guidelines on priority sector lending encourage banks to finance renewable energy projects by including them in their priority lending targets. This policy aims to boost the adoption of clean energy technologies and help India meet its renewable energy goals. Loans are extended to enterprises and households for investments in solar, wind, and other renewable energy sources.
  • Green Deposits Framework (RBI)
    The Green Deposits Framework, introduced by the RBI, requires regulated entities to establish board-approved policies for the allocation of green deposits. These deposits are earmarked for financing environmentally sustainable projects, such as renewable energy, clean transportation, and waste management. The framework aims to channel financial resources into projects that contribute to environmental sustainability.

II. Social Legal Requirements in India

1. Human Rights Laws (Constitutional Provisions)
The Indian Constitution enshrines a broad range of fundamental rights that form the foundation of social legal requirements. Articles 14 to 18 guarantee equality before the law and prohibit discrimination based on religion, race, caste, sex, or place of birth, ensuring all citizens are treated fairly. Article 19 protects freedoms such as speech, association, and movement, while Article 21 guarantees the right to life and personal liberty, which courts have interpreted to include the right to livelihood and humane working conditions.

Articles 23 and 24 prohibit trafficking, forced labour, and child labour in hazardous industries, reflecting India’s commitment to protecting vulnerable populations. Article 46, a Directive Principle, directs the State to promote the educational and economic interests of Scheduled Castes, Scheduled Tribes, and other weaker sections, and to protect them from social injustice and exploitation. These provisions are supported by a range of statutes and enforcement mechanisms to ensure compliance and redressal.

2. Protection of Human Rights Act, 1993
The Protection of Human Rights Act, 1993, establishes the National Human Rights Commission (NHRC) and State Human Rights Commissions to investigate human rights violations and promote awareness. The NHRC has powers to inquire into complaints, intervene in court proceedings, and recommend remedial action to the government.

3. Labour Laws

  • Payment of Wages Act, 1936:
    The Act mandates the timely payment of wages to workers, typically by the last working day of the month. It prohibits unauthorized deductions and provides for the resolution of wage-related disputes through designated authorities.
  • Minimum Wages Act, 1948:
    This Act ensures that workers receive at least the minimum wage fixed by the government for different sectors and regions, preventing exploitation and poverty. It also regulates working hours, overtime pay, and conditions of work, contributing to the well-being of the labor force. Enforcement is carried out through labor inspectors and penalties for non-compliance.
  • Employees State Insurance Act, 1948 and Employees’ Provident Fund and Miscellaneous Provisions Act, 1952:
    These Acts provide social security benefits to workers, including retirement savings, medical care, and insurance against sickness, disability, and death for workers and their families. Employers and employees contribute to provident fund and insurance schemes, which are managed by statutory bodies.
  • Factories Act, 1948 & Shops and Establishment Act, 1960:
    These laws regulate working conditions in factories, shops, and commercial establishments, setting standards for health, safety, welfare, and leave entitlements. They require employers to provide safe workplaces, adequate ventilation, and sanitation facilities, and to limit working hours to prevent overwork. The Acts mandate regular inspections and empower authorities to enforce compliance.
  • Maternity Benefit (Amendment) Act, 2017:
    The Act provides for six months of fully paid maternity leave for women employees, as well as additional leave for miscarriage or medical termination of pregnancy. It also requires employers to provide nursing breaks and crèche facilities for young children.
  • Labour Codes (2019–2020):
    44 labour laws have been consolidated into four codes: Code on Wages, Industrial Relations Code, Code on Social Security, and Occupational Safety, Health and Working Conditions Code to streamline compliance, reduce complexity, and increase worker protection, including for gig and platform workers.

4. Gender and Social Equity Laws

  • Protection of Civil Rights Act, 1955:
    Also known as the Untouchability Offences Act, this law abolishes untouchability and protects the civil rights of marginalized communities. It prohibits discrimination in access to public places, services, and employment, and provides for the prosecution of offenders.
  • Equal Remuneration Act, 1976:
    This Act mandates equal pay for equal work for men and women, addressing gender-based wage discrimination in the workplace. It prohibits employers from discriminating in recruitment, promotion, and conditions of service on the basis of gender. The Act is enforced through labor authorities and provides remedies for aggrieved employees.
  • Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989:
    The Act defines specific offences against members of Scheduled Castes and Scheduled Tribes, including violence, humiliation, and social boycott. It establishes special courts for the speedy trial of cases and prescribes stringent penalties to deter discrimination and atrocities. Amendments have expanded protections for women and strengthened enforcement mechanisms.
  • Maintenance and Welfare of Parents and Senior Citizens Act, 2007:
    This Act obligates children and heirs to provide maintenance for their parents and senior citizens, ensuring their welfare and dignity in old age. It establishes tribunals for the speedy resolution of maintenance claims and prescribes penalties for neglect or abandonment.
  • The Transgender Persons (Protection of Rights) Act, 2019:
    The Act recognizes the rights of transgender persons and prohibits discrimination in education, employment, healthcare, and access to public services. It provides for the issuance of identity certificates and mandates the establishment of welfare schemes and grievance redressal mechanisms.
  • Medical Termination of Pregnancy (Amendment) Act, 2021; Assisted Reproductive Technology (ART) Regulation Act, 2021; Surrogacy Regulation Act, 2021:
    These laws expand access to safe and legal abortion services, regulate assisted reproductive technologies, and ban commercial surrogacy while allowing altruistic surrogacy for Indian citizens.

III. Governance Legal Requirements in India

1. Companies Act, 2013

  • Section 149:
    This section requires certain classes of companies to have a specified number of independent directors, including at least one female director, on their boards. Independent directors are expected to bring objectivity and balance to board decisions, and to safeguard the interests of minority shareholders and other stakeholders.
  • Section 166:
    Section 166 outlines the duties of company directors, mandating them to act in good faith and in the best interests of the company, its employees, shareholders, the community, and the environment. Directors must avoid conflicts of interest and act with due care, skill, and diligence in discharging their responsibilities.
  • Section 134:
    This section requires the Board of Directors to prepare an annual report that includes information on the company’s financial performance, conservation of energy, and other ESG-related disclosures. The report must be presented to shareholders at the annual general meeting and filed with the Registrar of Companies.
  • Section 178:
    Section 178 mandates the constitution of Nomination and Remuneration Committees and Stakeholders Relationship Committees for companies with more than 1,000 security holders. These committees oversee the appointment and remuneration of directors and resolve grievances of shareholders and other stakeholders.
  • Schedule IV:
    Schedule IV sets out the code of conduct for independent directors, emphasizing their role in safeguarding the interests of all stakeholders, particularly minority shareholders. It requires independent directors to ensure the company has adequate vigil mechanisms, report unethical behavior, and balance conflicting stakeholder interests.

2. Corporate Social Responsibility (CSR) Requirements (Section 135 and Schedule VII)

Applicability and Committee Formation
Section 135 of the Companies Act, 2013, mandates that every company, including its holding and subsidiary companies, and certain foreign companies operating in India, must comply with CSR requirements if they meet any one of the following financial criteria during the immediately preceding financial year:

  • Net worth of ₹500 crore or more;
  • Annual turnover of ₹1,000 crore or more;
  • Net profit of ₹5 crore or more.

Such companies must constitute a Corporate Social Responsibility Committee of the Board, with at least three directors (including one independent director, where applicable). The Committee formulates and recommends a CSR policy, recommends the amount to be spent, and monitors the policy’s implementation.

The 2% CSR Spending Rule
Section 135(5) requires qualifying companies to spend at least 2% of their average net profits made during the three immediately preceding financial years on CSR activities. Net profits are calculated as per Section 198 of the Act. If a company fails to spend the required amount, the Board must specify the reasons in its annual report. Unspent amounts must be transferred to a fund specified in Schedule VII or, for ongoing projects, to a special “Unspent CSR Account” within prescribed timelines, with penalties for default.

Administrative and Reporting Requirements
Administrative overheads for CSR cannot exceed 5% of total CSR expenditure. Any surplus from CSR activities must not form part of business profits and must be reinvested in CSR. Companies must disclose the composition of their CSR Committee and details of CSR activities in the Board’s Report under Section 134(3).

Schedule VII: Eligible CSR Activities
Schedule VII provides an illustrative list of activities for CSR spending, including:

  1. Eradicating hunger, poverty, and malnutrition; promoting health care and sanitation; safe drinking water.
  2. Promoting education, including special education and employment-enhancing vocational skills, especially among children, women, the elderly, and the differently abled; livelihood enhancement projects.
  3. Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; old age homes, day care centers; reducing inequalities faced by socially and economically backward groups.
  4. Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources, and maintaining the quality of soil, air, and water.
  5. Protection of national heritage, art, and culture, including restoration of buildings and sites of historical importance; setting up public libraries; promotion and development of traditional arts and handicrafts.
  6. Measures for the benefit of armed forces veterans, war widows, and their dependents.
  7. Training to promote rural sports, nationally recognized sports, Paralympic sports, and Olympic sports.
  8. Contribution to the Prime Minister’s National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief, welfare of Scheduled Castes, Scheduled Tribes, other backward classes, minorities, and women.
  9. Contributions to incubators or R&D projects in science, technology, engineering, and medicine, funded by government bodies or public institutions.
  10. Contributions to public-funded universities, IITs, and national research bodies such as DRDO, ICAR, CSIR, and others.
  11. Rural development projects.
  12. Slum area development.
  13. Disaster management, including relief, rehabilitation, and reconstruction activities.

Failure to comply with CSR spending and transfer requirements attracts monetary penalties for both the company and responsible officers.

3. SEBI Regulations (Listing Obligations and Disclosure Requirements—LODR, 2015)
The LODR Regulations, 2015, issued by the Securities and Exchange Board of India (SEBI), establish comprehensive requirements for the governance and disclosure practices of listed companies. They mandate board composition standards, including the presence of independent directors and mandatory committees such as audit and nomination committees. The regulations require prompt disclosure of material events, transparent reporting of related party transactions, and maintenance of a functional company website with investor information.

4. Business Responsibility and Sustainability Reporting (BRSR, BRSR Core)

  • BRSR (2021):
    The BRSR framework, introduced by SEBI, requires the top 1,000 listed companies to disclose their performance on a broad set of ESG indicators, based on the National Guidelines for Responsible Business Conduct (NGRBC). The disclosures cover areas such as ethics, transparency, employee well-being, stakeholder engagement, human rights, environmental stewardship, inclusive development, consumer welfare, and policy advocacy. The aim is to promote responsible business practices and facilitate informed decision-making by investors and stakeholders.
  • BRSR Core (2023):
    BRSR Core is a streamlined subset of the full BRSR, focusing on a core set of key ESG performance indicators tailored for the Indian context. It introduces phased assurance requirements for the top listed companies and their value chain partners, enhancing the reliability and comparability of ESG disclosures. The framework is designed to facilitate benchmarking and assurance, and to drive continuous improvement in ESG performance.

5. Anti-Corruption and Money Laundering Laws

  • Prevention of Corruption Act, 1988:
    This Act criminalizes bribery and corruption in public and private sector transactions, prescribing stringent penalties for offenders. It empowers authorities to investigate and prosecute corruption cases, and provides for the confiscation of ill-gotten assets.
  • Prevention of Money Laundering Act, 2002:
    The Act establishes a legal framework to prevent and penalize money laundering, requiring regulated entities to maintain records, conduct due diligence, and report suspicious transactions. It provides for the attachment and confiscation of proceeds of crime, and empowers enforcement agencies to investigate and prosecute offenders.

If you want me to add anything I’ve missed, please leave a comment about it, and I’ll work on it. Thanks.

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